Department of Commerce, Bureau of Industry and Security is rescinding the April 20, 2024 firearms and ammunition related Interim Rule is going to be “…rescinded in its entirety—with the only exception being to maintain new Export Control Classification Numbers (ECCNs). This final rule also amends the EAR by removing the Congressional notification requirement for certain semi-automatic firearms license applications.”  Per Federal Register notice to be posted tomorrow, September 30^th, 2025.

This rule removal removes the “CC 2” control for most destination countries – meaning that the optics and shotguns that did not need US export licenses for many worldwide destinations before the Interim Final Rule, again, don’t need US export licenses.  Also, the “CC 2” control feature caused many destinations to not be eligible for EAR license exceptions, such as Low Value Shipment (LVS), Temporary Import/Export (TMP), and Servicing and Replacement (RPL) – which are all to be usable again for destinations not listed in the Country Group D or E country group listings or still have the “CC 2” marked in the Country Control Chart.  And the list of 36 countries “High-Risk Destinations” has been emptied of destinations for firearms and ammunition products that had created a BIS policy of denial for such items to these destinations for commercial resale.

To further remove bureaucratic processing delays, the “Congressional Notification” has been removed.

Also, the Interim Final Rule’s additional administrative burdens requiring extra supporting paperwork – such as the import authorization and purchase order type documents – have been removed and reset to the prior requirements.  The import license or permit if required by the destination country’s import processes is, like it was before, still required to have in your records before the shipment departs the U.S. Note that even though BIS-711/End User Certification forms may not be officially required (as they were not previously), it is still HIGHLY RECOMMENDED to still gain these customer acknowledgements of the US export controlled nature of these items.  A purchase order type document is not required anymore.  Locations that required an import authorization document before the Interim Final Rule, one is still required – this is mostly the Americas due to the Organization of American States (OAS) treaty obligations and referenced by BIS as an FC Import Certificate.

And the 4-year license validity period is back!

A few things did stay…

They did keep “CC 2” reason for control, but it seems much more appropriately used.

The Electronic Export Information (EEI) filing on the shipment prior to it departing the US still requires that the line item entry include the items’ paragraph classification other control descriptor in the first text in the Commodity Description block – meaning for 0A501.a firearms, the “a” would be the first entry in the description block followed by the description text as the “0A501” part of the control descriptor would be entered in the ECCN data block.

And the “new” ECCNs for semi-automatic firearms stayed.

If you’d like to review the full commentary and all the changes, this rule can be downloaded at  https://www.federalregister.gov/public-inspection/2025-18992/revision-of-firearms-license-requirements  – and the official final rule webpage when release September 30, 2025.

If you need assistance navigating the Export Administration Regulation, BIS, ITAR, DDTC, SNAP-R, DECCS, or how to do any of the other many requirements the USG expects for EAR or ITAR compliance, our Orchid Advisors Export Support team can help.